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1 (ons) Response to consultation on insurance companies' recording of pensions transactions Introduction In January 2004 ONS published a consultation note on insurance companies' recording of pensions transactions, highlighting a number of issues that had been investigated as part of the review of surveys of insurance companies and self-administered pension funds. The discussion note was circulated widely to the Association of British Insurers (ABI), to the National Association of Pension Funds (NAPF) and to academics and policy researchers in the pensions field. Meetings were held with insurance companies and the ABI, and with NAPF and members of their Investment Council. We thank all those who responded and the ABI and NAPF for their assistance in arranging meetings. This note reports on the results of the consultation. General points There was agreement that there is a need for good data on all employer sponsored pension provision whether it is final salary, money purchase or personal pensions and on individual pension provision. The data collected by ONS in its MQ5 surveys of insurance companies and self-administered pension funds are primarily for National Accounts although they are also used as an input for policy development. It is important that there is clarity about the statistics and that each pension contribution is counted correctly. There is demand for more detail and for more data some of which might be met by linking data sets from a range of sources. Response: The work of the Pension Statistics Review Committee during 2003/04 encompassed a review of some major surveys on different aspects of pension data, and looked at potential sources for longitudinal analysis. The review of the ONS questionnaires for insurance companies highlighted areas where there was inconsistent reporting and where additional detail was required. New questions were included in the surveys to collect additional data on transfers, premium income from insurance managed funds and a breakdown of personal and occupational pension premiums. The revisions included more specific guidance and notes for insurance companies in completing the questionnaires, particularly in relation to personal and group/company sponsored pension premiums. In the self-administered pension fund survey the questionnaire was changed to collect a breakdown of contributions between defined benefit, defined contribution and hybrid schemes. The results from the new questionnaires will be monitored through 2004 and the impact of the changes evaluated to ensure consistency of reporting. The questionnaires will be kept under review, in consultation with the pensions sector, to allow developments in the industry, trends in products and the impact of legislative and policy changes to be captured. Differences in internal company reporting and industry developments may make it necessary to collect a detailed, product breakdown of pension premiums, although this would have to be balanced against the costs of collection. As part of the re-engineering of the financial surveys over the next two years, we will be looking at the scope for linking data from the MQ5 surveys with other surveys and with administrative and regulatory data sources to provide a more detailed source for analysis. Other proposals, such as the

2 development of a wealth and assets survey should, in time, provide more data on potential income in retirement. ONS has established a cross-departmental Pension Statistics Task Force whose remit includes listing gaps in data and priorities for filling them as well as investigating the potential for data linking. The Task Force will be producing a Pensions Trend report to provide a source statistical document. Potential double counting areas 1. Group Personal Pensions Group personal pensions (GPPs) are personal pension plans that an employer has organised for a group of employees, usually with an insurance company or other financial institution. For regulatory and taxation purposes they are identical to individual personal pensions, and so are included in the Inland Revenue data for personal pensions. As part of the testing of new questionnaires we asked respondents where they reported GPPs. Discussion with the Association of British Insurers (ABI) had led us to believe that these would be reported as personal pensions. In reconciling pension contributions data, it was assumed that GPPs are part of personal pensions. Using the table in Annex B of the pensions review report, personal pension contributions (from MQ5) are subtracted in line G and Inland Revenue data for personal pension contributions are added back in line M. To the extent that GPPs are being reported as occupational pensions in MQ5, then total pension contributions and contributions to funded occupational schemes will be overstated. Response: In our investigations, most of the respondents said they reported GPPs under group sponsored (ie occupational) pensions. The treatment of GPPs and employer stakeholder pensions is a live issue for insurance companies. The pensions business market has developed into two streams: employer related and individual related business. ' internal reporting systems, which are used to track market share, reflect this evolution with GPPs and employer stakeholder pensions being viewed as corporate business sold to business channels. This would explain why GPPs were being reported as group/company sponsored business on the MQ5 questionnaires. thought that there may be an issue in future under pension simplification as to how occupational pensions and GPPs would be split. From 2004, we are explicitly asking respondents to include GPPs under personal pensions on the new quarterly questionnaires and we have asked for data on GPPs separately on the annual questionnaire for This change on the MQ5 questionnaires will be reflected in the results from 2004, and it is likely that it will cause revisions to the MQ5 data. who responded to the consultation confirmed that they would be able to provide the data as requested. We are aiming to produce an estimate of the discontinuity in pension contributions caused by GPPs. 2. Insurance managed funds There is potential double counting of pension contributions which flow from the self-administered pensions sector into insurance managed funds. In the self-administered pension funds survey, contributions are reported on the income and expenditure questionnaire, and investment in insurance managed funds (and insurance policies and annuities) is shown on the transactions questionnaire and annual balance sheet. The extent to which this flow of funds is regarded by insurance companies as part of its pensions business and is reported by them as pension premiums will lead to double counting in the published estimates of pension contributions Response : Pension funds confirmed that contributions would flow from them to insurance companies in this way and that they would report this flow as investment in insurance managed funds on the transactions questionnaires. As part of our investigations we confirmed with insurance companies whether they had included premiums from insurance managed funds in their group sponsored (occupational) pension returns

3 or reported them as "other business". Where companies wrote this business, most said they had included these premiums under group sponsored (occupational) returns. thought that the business that may be reported as pensions premiums would be those managed funds written as an insurance contract rather than asset managed business. There was also the possibility that movements of assets among insurance managed funds may be reported along with new pensions business. From 2004, we are asking respondents for data on premium income from insurance managed funds separately on the new quarterly questionnaire for 2004 and on the annual questionnaire for In future, premium income from insurance managed funds will be excluded from estimates of pension contributions published in Annex B of the pensions review report. We will assess the impact of this change on the results through Group additional voluntary contributions Group additional voluntary contributions (that is avcs paid by members of an occupational scheme to buy additional benefits) data are collected separately in the self-administered pension funds survey. These contributions might also be included on the long-term insurance income and expenditure questionnaire from those insurers who write this business. The methodology used to reconcile pension contribution statistics in the table in Annex B of the review report assumes that group avcs are not included in group/company sponsored pension premiums reported by insurance companies. Response : Pension funds said most group avcs would be passed to insurance companies, and reported on the transactions questionnaire as investments in insurance managed funds or in mutual funds. The only occasion when pension funds would not pass these on would be where the avcs bought additional years or other defined benefits and the contributions would be held by the self-administered pension fund as part of its funds. According to the National Association of Pension Funds, in 2002, only 15 per cent of private sector group/company sponsored schemes offered additional years and 9 per cent another form of defined benefit avc. confirmed that group avcs passed to them by pension funds would be reported as group/company sponsored pension premiums. The revised long-term insurance questionnaire asks for group avcs to be reported under group/company sponsored pension business. Group avcs are collected separately on the selfadministered pension funds questionnaire and they can be excluded from pension contributions estimate. We will provide an estimate of the discontinuity caused by excluding group avcs from pension contributions. 4. Bulk buyouts Bulk buyouts arise when a self-administered fund winds up and purchases policies from insurance companies to provide benefits for their members. Premiums from bulk buyouts would be reported by insurance companies on the income and expenditure form. Previously these premiums would have been reported by the self-administered funds as contributions. While we have been unable to find a self-administered fund which has continued to return questionnaires through to wind-up and we do not know how bulk buyouts would be reported by them, discussion with OPRA suggest that they might be reported as transfer payments. Response : would have reported bulk buyouts as group/company sponsored pensions business although the premiums would not always have been new pension contributions. It was possible that where a scheme was winding up and there was a deficit, the company might make top-up payments. These additional payments would be new pension contributions. writing this business will be able to report these premiums separately on the new questionnaires from the first quarter In future, bulk buyouts will be excluded from estimates of pension contributions. We will provide an estimate of discontinuity to estimates of pension contributions published in Annex B of the pension statistics review report caused by bulk buyouts.

4 We will need to develop ways of confirming whether top-up payments have been included in the returns either from insurance companies reporting this business or from the pension scheme. Other issues investigated 1. Group life premiums Group life premiums are for life assurance, provided as an additional benefit for pensions contributors, not direct pension contributions. In discussions with the ABI, it was suggested that insurers might be including group life cover premiums, where this was a benefit purchased by the pension scheme, under pension premiums rather than under life. Response : We investigated this with respondents as part of the various consultation exercises. Some of the companies contacted said they included these premiums under pensions; other companies writing this business included these under life assurance or permanent health. For insurance companies, this business has a historic affinity with defined benefit schemes where group life cover was included as an integral part of the pension scheme paid from contributions. As companies have reviewed their pension provision, group life cover could have become a separate contract paid for by the company. This is likely to be the case where provision has been shifted to group/company sponsored defined contribution schemes and group personal pensions. Some insurance companies will consider group life cover to be part of their pensions business, while others would consider it to be part of their life business. While group life cover premiums are not pension contributions, pension funds may well use this cover to pay dependants' benefits in the event of death in service. Pension funds confirmed that they have been changing the way they purchase group life cover over time. Some pension funds will keep these as an integral part of the pension provision while others will purchase them separately. We have asked insurance companies to report group life cover under group (occupational) pension premiums. For National Accounts, premiums paid for group life cover as part of the pension package would be regarded as compensation of employees and included in pension contributions. For pension policy purposes, the DWP want these premiums excluded from pension contributions, and we will consider asking for this business to be reported separately when the questionnaire is next revised. 2. Single premiums It has been suggested that group (occupational) single premiums reflect mainly movement of assets from the self-administered sector to insurance companies and movement of assets between insurance companies. Movement of assets between insurance companies will be reflected in adjustments for transfers made by National Accounts. Response : According to insurance companies, there is single premium business being written, such as small self-administered schemes, executive pension schemes and companies topping up shortfalls on existing schemes. They considered that most of the single premium business is likely to be money being moved around from one insurance company to another which will be transfers rather than new money. Pension funds confirmed this. The revised questionnaires include questions on transfers in and out of pension business for group/company sponsored and for individual/personal pension premiums. These results should help identify movements of funds more directly than current methodology and should provide a breakdown between group/company sponsored and individual/personal pension premium transfers. The estimates of transfer payments to group/company sponsored pension business will be subtracted from single premiums enabling them to be cross checked with other data sources. 3. register The register used for the insurance companies survey is based on regulatory data. This list has been checked to ensure that companies included in the universe have insurance provision as their main business rather than fund management.

5 Other issues not yet investigated In discussing the findings of our investigations, a number of other issues have been raised which have not yet been fully followed through: 1. Additional voluntary contributions The issue of how pension schemes report employee additional voluntary contributions where these buy added years rather than money purchase benefits. It was suggested that these contributions might be retained as part of the overall fund rather than be passed on to insurance companies. Response : See under group additional voluntary contributions above (3) 2. "Key man policies" The issue of where insurance companies report contributions to a personal pension scheme where the employer also contributes. While this should be reported as personal/individual contributions, there is a possibility that this may have been reported under group/company sponsored. Response : said that they would be unlikely to distinguish these payments from GPPs and it is unlikely to be significant business. The changes to the notes and guidance on the revised questionnaires should ensure that these are reported, like GPPs, as individual/personal pension premiums. 3. Pension annuities Some pension schemes buy out their pension commitments to their retirees by buying annuities from insurance companies. The issue of where insurance companies have been reporting the purchase of pension annuities and income drawdown has been raised. We believe that these are being reported as personal/individual pension premiums. This would overstate the personal pension premiums reported in our MQ5 survey, although it would not affect any other estimates as Inland Revenue administrative data is used for personal pension contributions. Response : differ as to how these are treated internally. It is likely that the companies will report them as personal pensions on the questionnaire. The revised notes and guidance on the questionnaire ask for this business to be reported as individual/personal pension business although these are not new pension premiums. When the questionnaire is next revised, we will ask for this business to be reported separately. The ABI collect this business as a separate item and we will use that data to cross check our estimates of personal pension contributions against IR administrative data for personal pensions. Plans for publication The new questionnaires have been used from the first calendar quarter 2004 and for the 2003 annual survey. Quarterly results published will be moved on to the new basis during 2004 including Annex B of the pensions review report which will exclude the double counting and missing flows. It is possible that this may cause discontinuities in the MQ5 dataset which feed through into National Accounts. The extent of these will not be known until the annual survey for 2003 (using the new questionnaire) can be compared with the original quarterly results, although steps will be taken to preserve the continuity of aggregate series in the National Accounts. Revisions to earlier periods would then be available for Blue Book May 2004

6 ISSUE Group Personal Pensions (GPPs) Insurance managed funds Group additional voluntary contributions (AVCs) Bulk buyouts Group life premiums CONSULTATION RESPONSE treat these as employer related. They are able to report them under personal pensions. Pension funds and insurance companies confirmed that the funds flow between them as described. Insurance companies thought that there was a possibility that movement of assets among insurance managed funds may be reported along with new pensions business were confident that pension funds would be passing on group avcs to them, unless these bought additional years or other defined benefits when the pension fund would hold them as part of its fund. Insurance companies would report them under group/company sponsored business have reported bulk buyouts under group pensions business. There may be new money included if the scheme was in deficit and a top-up payment was made. differ in how they treat these. Some consider them to be part of their pensions business and others consider them to be part of their life business. Pension funds have also changed the way they buy this cover with some purchasing it separately and others seeing it as part of their pensions business ONS TREATMENT GPPs are treated as personal pensions for National Accounts. The revised questionnaires ask for GPPs to be reported under personal pensions. We intend to estimate discontinuities to pension contribution estimates caused by this change We are asking for premium income from insurance managed funds to be reported separately on the revised questionnaires. These premiums will be excluded from the estimates of pension contributions. We intend to estimate discontinuities to pension contribution estimates caused by this change We are asking for group avcs to be reported as group/company sponsored pension business on the revised insurance questionnaires. Group avcs are collected separately on the pension funds questionnaire and these will be excluded from estimates of pension contributions. We intend to estimate discontinuities caused by this change We are asking for bulk buyouts to be reported separately on the revised questionnaire and they will be excluded from the pension contributions data. We will explore ways of collecting top-up payments We have asked insurance companies to report group life cover under group pensions business. National Accounts regard these premiums as compensation of employees and include them in pension contributions. For pension policy, DWP want these contributions excluded from pension contributions, and we will consider asking for them separately when the questionnaires are next revised.

7 Single premiums Key man policies Pension annuities write some single premium group pension business although they consider that much of the single premium business is funds being transferred from insurance company to another. said they would be unlikely to distinguish this business from GPPs and it is unlikely to be significant differ as to how these are treated internally. It is likely that this business is reported under individual/personal pensions We are asking for a more detailed breakdown of transfers between group pension business and individual/personal pension business. This should allow transfers to be deducted from single pension premiums and the results to be cross checked against other data sources. The changes to the guidance notes on the insurance questionnaires should ensure that these are reported under individual/personal pensions business We are asking for these purchases to be reported under individual/personal pensions. When the questionnaires are next revised, we will ask for this business to be reported separately. We will use ABI estimates for this business to adjust our personal pension data and cross check our estimates with Inland Revenue administrative data for personal pensions. 26 May 2004

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